Customer identification: Data to be collected under the new EU AML Regulation

The new EU AML Regulation (Regulation (EU) 2024/1624 of the European Parliament and of the Council on the prevention of the use of the financial system for the purposes of money laundering or terrorist financing) replaces large parts of the national anti-money laundering frameworks. For the first time, this establishes a directly applicable, uniform European AML rulebook.

This also brings revised requirements for the data to be collected during customer identification.

Compared to the existing obligations under the German AML Act (GwG), numerous details are changing. Obliged entities must prepare to adapt their internal processes and systems to meet the stricter and expanded requirements of the EU AML Regulation.

The following two tables provide an overview of the key differences between the GwG and the EU AML Regulation, with regard to natural and legal persons.

Natural persons – mandatory information for identification

The following overview shows in blue which mandatory information must be collected according to Art. 22(1)(a) EU AML Regulation, in comparison to the German AML Act (black), when identifying natural persons:

Identification of natural person AMLA vs EU AML Regulation - Customer identification: Data to be collected in future under the EU AML Regulation - Regpit

Legal persons – mandatory information for identification

The following overview shows in blue which mandatory information must be collected according to Art. 22(1)(b) EU AML Regulation, in comparison to the German AML Act (black), when identifying legal persons:

Identification of legal entities AMLA vs EU AML Regulation - Customer identification: Data to be collected in future under the EU AML Regulation - Regpit

Practical implications and implementation

The EU AML Regulation will apply from 10 July 2027. As of this date, obliged entities under anti-money laundering law must have integrated the above-mentioned — and many additional — requirements of the EU AML Regulation into their KYC processes. In this context, the draft Regulatory Technical Standards (RTS) on customer due diligence (CDD requirements) pursuant to Art. 28(1) EU AML Regulation issued by the European Banking Authority (EBA) should also be taken into account. This RTS draft further specifies which information obliged entities will be required to collect as part of the KYC process going forward. This draft RTS further specifies which information obliged entities must collect in future as part of the KYC process.

To the RTS draft